Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’s Comp Act

In Muse v. Daimler Trucks N. Am., 2025 N.C. App. LEXIS 113 (Mar. 19, 2025), the North Carolina Court of Appeals affirmed the Industrial Commission’s denial of workers’ compensation benefits to a long-time employee who claimed psychological injury resulting from a disciplinary meeting. The appellate court agreed that the meeting was not an “accident” within the meaning of N.C. Gen. Stat. § 97-2(6), and thus, any injury arising from it was not compensable under the Act.

Background

James K. Muse, a Daimler Trucks employee since 1984, alleged he developed anxiety, depression, and insomnia following an August 2018 HR meeting in which he received a final written warning for allegedly harassing a colleague. Muse claimed that the unexpected nature of the meeting, coupled with the disciplinary action and the refusal to allow a second union representative to stay, constituted an “accident” under the Act. A deputy commissioner initially agreed, finding that Muse’s psychological symptoms were causally related to the event and awarding benefits.

The Full Commission, however, reversed, finding that the disciplinary process—while possibly stressful—did not rise to the level of an “unusual or untoward event” required to satisfy the statutory definition of an “accident.”

Appellate Court’s Analysis

The appellate court affirmed the Full Commission’s ruling. Citing a series of precedents—including Pitillo v. N.C. Dep’t of Envtl. Health & Nat. Res., 151 N.C. App. 641, 566 S.E.2d 807 (2002), and Knight v. Abbott Labs., 160 N.C. App. 542, 586 S.E.2d 544 (2003)—the court reiterated that not every emotionally difficult personnel interaction constitutes an accident under North Carolina law.

The court stressed that an “accident” under N.C. Gen. Stat. § 97-2(6) requires both An interruption of the work routine, and ihe introduction of unusual conditions likely to produce unexpected consequences. The court noted that Daimler had followed its usual HR protocols: Muse was notified per company policy, allowed union representation, and given the chance to respond to the allegations. Testimony from HR personnel confirmed that disciplinary meetings were commonly unannounced and handled in a direct, but not hostile, manner.

The court added that while Muse may have experienced distress, a claimant’s subjective emotional reaction did not transform a routine disciplinary meeting into an “accident” under the Act. The court wrote:

Plaintiff’s subjective shock or disappointment does not convert a personnel meeting into an “accident,” [referencing Gray v. RDU Airport Auth., 203 N.C. App. 521, 692 S.E.2d 170 (2010)].

Comment

Muse continues a long-standing trend in North Carolina workers’ compensation jurisprudence: efforts to recover for workplace stress or psychological harm must meet the demanding threshold of demonstrating a truly unexpected and untoward event. Routine employer actions—however distressing—do not, by themselves, meet that standard.

Attorneys handling mental injury claims in North Carolina should tread carefully when the triggering event involves ordinary personnel procedures. Unless the facts show a clear break from the expected course of workplace interactions, courts are unlikely to find the necessary “accident” element under N.C. Gen. Stat. § 97-2(6).